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 (1) Where at any time a person transfers property, either directly or indirectly, by means of a trust or by any other means, to   (a) the transferor’s spouse or common-law partner or an individual who has since become the transferor’s spouse or common-law partner,   (b) an individual who was under eighteen years of age, or   (c) another person with whom the transferor was not dealing at arm’s length, the transferee and transferor are jointly and severally liable to pay under this Part an amount equal to the lesser of   (d) the amount determined by the formula   A- B Where   A  is the amount, if any, by which the fair market value of the property at that time exceeds the fair market value at that time of the consideration given by the transferee for the transfer of the property, and B  is the amount, if any, by which the amount assessed the transferee under subsection 160(2) of the Income Tax Act in respect of the property exceeds the amount paid by the transferor in respect of the amount so assessed, and   (e) the total of all amounts each of which is      (i) an amount that the transferor is liable to pay or remit under this Part for the reporting period of the transferor that includes that time or any preceding reporting period of the transferor, or      (ii) interest or penalty for which the transferor is liable as of that time, but nothing in this subsection limits the liability of the transferor under any provision of this Part.      325 ...

After a lengthy hearing, and based on extensive oral testimony (including factual evidence and the evidence of experts), a voluminous documentary record, and a legal analysis that included consideration of the language, context and legislative history of section 143, Justice Campbell concluded that section 143 does not apply to the Bountiful community because it is not a “congregation” within the definition quoted above. ...

Moreover, the judge did not take into consideration the duties of these two trustees under the Civil Code of Québec, S.Q. 1991, c. 64 (articles 1261, 1278, 1309 and 1310). [30]            Lastly, the appellant criticizes the judge for ignoring basic information, namely, that Lyrtech was a public company and that it had seven (7) shareholder-elected directors. ...

The Corporation assumed the existing mortgage on the Property and paid nominal consideration to the co-investors. [12]         The evidence shows that starting around 1991 the Appellant devoted a significant portion of his time to the redevelopment of the Property. ...

However, without deciding whether it is necessary to do so, given that all parties at the hearing clearly understood that this was an appeal of the reassessment of April 18, 2016, given that pursuant to subsection 18.15(3) of the Tax Court of Canada Act appeals “shall be dealt with by the Court as informally and expeditiously as the circumstances and considerations of fairness permit” and given the inherent powers of this Court as a superior court of record to govern its own process, on my own motion, I hereby amend the appeal to be an appeal against the reassessment of April 18, 2016. [2] See the top half of the first page of the exhibit. [3] Still in the top half of the first page of the exhibit. [4] Within the family it is very unlikely one would choose to change the bill to a different member of the household temporarily. [5] Paragraph (a) of the definition of “principal residence” in section 54 of the Income Tax Act. ...

Delongchamp entitled “ Forming an Operating Limited Liability Companies Canadian and US Tax Considerations ” at the bottom of page 19). ...

She noted that the amount in issue was significant for this Court, some 2 million dollars; that it was a test case for many other similar files before the Revenue Agency; and that there were very complicated financial arrangements under consideration involving at least four major GST issues. ...

The Queen, [6] Judge Bowman’s discussion of novelty, uniqueness, complexity, difficulty and the fact that a large amount of money is involved was in the context of awarding solicitor-client costs, which are far above Tariff costs and involve considerations entirely separate from the Court’s general authority to exercise its discretion in applying the section 147 factors ...

It is all very well to state that it is for the trier of fact to assess the claimant’s knowledge, but the assessment must be based on the evidence on the record, disregard considerations excluded by the case law and take into account any presumptions that may apply. ...

It went on to summarize the basis upon which the request was being denied. [11]            In that regard, the letter noted that particular consideration was given to Mr. ...